Attachment Explanatory Stmt

This document pretains to SES-STA-20170522-00579 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017052200579_1230139

Row 44, Inc. STA Request May 2017 EXPLANATORY STATEMENT Row 44, Inc., pursuant to Section 25.120(b) of the FCC’s Rules, hereby requests Special Temporary Authority (“STA”) for an initial period of sixty (60) days to operate its licensed Ku- band Earth Stations Aboard Aircraft (“ESAA”) network (Call Sign E080100) using additional points of communication and a new, next generation antenna. In particular, Row 44 seeks to use space segment capacity on two SES, S.A. (“SES”) satellites, AMC-3 at 72 W.L. (“AMC-3”) and SES-10 at 67 W.L. (“SES-10”), using both its currently licensed Ku-band antenna and the TECOM/QEST GSAA antenna that is subject of its pending license modification application. See FCC File No. SES-MFS-20170221-00188 (originally filed as SES-MFS-20170126-00061), as amended by SES-AMD-20170414-00395. Row 44 is currently authorized under an existing STA to transmit to AMC-3 at the 72 W.L. orbital location using the licensed antenna (originally granted in FCC File No. SES-STA- 20161223-00972 and most recently extended on May 8, 2017 in FCC File No. SES-STA- 20170503-00495). By this request it seeks additional authority to use, on a limited basis, the newer GSAA antenna and to make use of SES-10, which is replacing AMC-3’s prior operation at 67 W.L., pending final action on the modification application. STA is sought for all antennas currently authorized and operating under Row 44’s existing FCC license. Although a total of 1,000 Ku-Stream antennas are authorized under this license, only about 650 are installed on aircraft operating in U.S. airspace, and only a portion of this total are operating concurrently at any one time. For the newer GSAA antenna that Row 44 seeks to add to the license permanently via the pending modification application, Row 44 seeks initial authority to operate up to twenty (20) mobile units during the sixty (60) day period beginning on June 1, 2017. Row 44’s operations on both AMC-3 at 72 W.L.and SES-10 at 67 W.L. will not cause harmful interference to any adjacent satellites operating consistent with FCC's two-degree spacing policy. Attached are coordination certification letters from SES, in accordance with Sections 25.227(b)(2) of the Commission’s Rules, that cover these proposed operations, which will also be consistent with its existing, long-term coordination agreements with the National Science Foundation and the National Aeronautics and Space Administration pursuant to which the existing ESAA license was granted. Under Section 25.120(b)(1) of the FCC’s Rules, the International Bureau may grant an STA when the public interest supports the relief requested, and/or delay in the institution of temporary operations would be contrary to the public interest. See 47 C.F.R. § 25.120(b)(1). Such authority may be granted for a period not to exceed 60 days where the applicant has filed a request for permanent authority for the parameters and facilities requested. See 47 C.F.R. § 25.120(b)(3). This is the case here, where Row 44 has filed an application to modify its license permanently to permit access to AMC-3 at its new 72 W.L. orbital location and recently

Row 44, Inc. STA Request May 2017 Page 2 of 2 amended that pending application to add SES-10 at 67 W.L. as a point of communication as well (see FCC File No. SES-AMD-20170414-00395). Grant of the authority requested here will promote the public interest by permitting Row 44 to provide ongoing service to its customers using capacity on both requested satellites. Continued use of AMC-3 at 72 W.L. will maintain effective coverage of all U.S. domestic routes currently served by Row 44. Additional use of SES-10 will allow Row 44 to serve customers that previously received service using AMC-3 and AMC-6 at the 67 W.L. orbital location Grant of the requested STA is consistent with Commission policy and will not adversely affect other authorized operations. Row 44 acknowledges that any action taken pursuant to a grant of the requested STA will be at its own risk, and respectfully requests that the FCC grant it updated authority as of June 1, 2017, for a period of sixty (60) days, to use the AMC-3 and SES-10 satellites as points of communication in the conventional Ku-band using both the TECOM antennas now operating under its FCC ESAA network license as well as additional, improved antennas for which full authority is sought in its pending modification application.


Document Created: 2017-05-22 17:15:17
Document Modified: 2017-05-22 17:15:17
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